The Mannheim Regional Division of the Unified Patent Court (UPC) issued a final order on December 22, 2025, in the case of InterDigital v. Amazon, upholding its unilateral anti-interim license injunction (AILI) issued on September 30, 2025. This order not only confirms the injunction's validity but also explicitly outlines specific sanctions for potential violations for the first time, including an initial penalty of up to €50 million (approximately RMB 414 million) and a daily penalty of €500,000 (approximately RMB 4.14 million).

On December 24, 2025, the UPC formally notified the European Commission's Directorate-General for Competition and Directorate-General for Trade of this decision, marking the escalation of this transnational patent jurisdiction dispute to the EU policy level.

The court's core positions are as follows: First, it ruled that the UK's “provisional license” system constitutes a disguised anti-suit injunction aimed at depriving patent holders of their litigation rights within the UPC. Second, it determined that this measure violates EU public policy and international rules such as TRIPS, rendering it invalid within the UPC's jurisdiction. Third, it clarified that it will not interfere provided the UK's final rate ruling remains strictly confined to its domestic territory without external extension.

The judicial confrontation began in late September 2025 when the Mannheim Division of the UPC and Munich Regional Court (Germany) issued unprecedented anti-provisional license injunctions at InterDigital's unilateral request, seeking to prevent Amazon from obtaining extraterritorially applicable provisional licenses through UK courts.

In response, the High Court of England and Wales (EWHC) swiftly granted InterDigital an ex parte anti-suit injunction (AASI) in October to protect its FRAND rate-setting proceedings in the UK. Despite disputes over the injunction's interpretation, the EWHC upheld its validity in subsequent hearings.

In November 2025, the Mannheim Division of the Unified Patent Court (UPC) held a hearing where the judge expressed reluctance to recognize licensing agreements imposed on patent holders by foreign courts. The judge suggested that an order from a UK court appeared to restrict InterDigital's freedom to present arguments before the UPC and might be directed against UPC judges. However, the EWHC judge later refuted this interpretation.

In late November, the Munich Regional Court I also held a preliminary injunction hearing and similarly upheld its anti-provisional license injunction.

In early December, the EWHC reaffirmed its anti-counterclaim injunction in a judgment.

Under procedural rules, Amazon may appeal this ruling within 15 days.

Scan the QR code to access the translated judgment (machine translation version).